Advanced Tax Strategies in Structuring Private Investment Funds: Balancing Competing Interests

$199.00

SKU: 410601

Description

Gain an understanding of critical fund structuring considerations in light of recent tax laws in order to better advise your clients.
Recent changes in the tax law require careful review of private investment fund and general partner structures, as well as consideration of potential amendments to the existing fund documentation to achieve tax efficiency. Many tax practitioners may not be aware of essential planning techniques to avoid tax pitfalls. This topic will review such factors as the type of investor, type of fund, location of fund, and general partner tax planning considerations. Fund professionals and advisers will benefit from this topics general overview of the typical structures and a deeper dive into current tax issues, such as the impact of the CARES Act, proposed carried interest regulations, and potential changes to the tax rates. This information is critical for professionals trying to stay ahead of the changes and better serve their clients.

Date: 2023-05-18 Start Time: 1:00 PM ET End Time: 2:40 PM ET

Learning Objectives

* You will be able to define ECI, UBTI, blockers, masterfeeder funds, management fee waivers, profits interests, and capital interests.

* You will be able to describe key U.S. federal income tax considerations important to nonU.S. investors investing in U.S. private investment funds.

* You will be able to explain the difference between the tax treatment of funds that are engaged in a U.S. trade or business and funds that are treated as investors (and how to distinguish between the two).

* You will be able to review and comment on tax disclosures and tax risk factors in a private placement memorandum for a typical investment fund.

Tax Structuring Considerations — Fund Level
• Choice of Entity
• Choice of Jurisdiction
• Advanced Structures: Parallel Funds, Master-Feeder Funds, Use of Blockers

Tax Structuring Considerations – Investor Level
• Tax Issues for U.S. Taxable Investors (Including Impact of Tax Reform)
• Tax Issues for U.S. Tax-Exempt Investors – UBTI and Structuring Solutions
• Tax Issues for Non-U.S. Investors – ECI and Structuring Solutions

Tax Structuring Considerations – General Partner and Fund Manager Level
• Carried Interest and Management Fee Structuring Considerations
• Tax Implications of the Grant of Profits Interests, Vesting Restrictions, Adding New Principals, and Other Common Manager Arrangements
• Proposed Section 1061 Carried Interest Regulations: Issues and Structuring Solutions

CPE ,Additional credit may be available upon request. Contact Lorman at 866-352-9540 for further information.

Olga A. Loy-Winston & Strawn LLP